Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The HC quashed the retrospective cancellation of the petitioner-assessee's GST registration, relying on Riddhi Siddhi Enterprises v. Commissioner of Goods and Services Tax (CGST), South Delhi & Anr. It held that in the absence of the show cause notice embodying an intent for retrospective cancellation, the cancellation shall be effective from the date of issuance of the show cause notice, not retrospectively.
The HC quashed the retrospective cancellation of the petitioner-assessee's GST registration, relying on Riddhi Siddhi Enterprises v. Commissioner of Goods and Services Tax (CGST), South Delhi & Anr. It held that in the absence of the show cause notice embodying an intent for retrospective cancellation, the cancellation shall be effective from the date of issuance of the show cause notice, not retrospectively.
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